privacy policy.

Last Updated: March 6, 2023

Introduction

Thank you so much for using shades, from Shades Media, Inc. ("shades")

shades is committed to making a positive impact in the lives of our users and on society. We do that by helping our users make sense of online news and information. For that reason, it is important for us to be trustworthy and credible stewards of all sorts of online information and data, including yours.

This document is the shades Privacy Policy. It outlines our collection and use of data, particularly user data.

Capitalized terms are defined terms, and have the meaning given in shades's Terms of Service, or as defined in this document.

Before you continue on into this Privacy Policy, we can say a few simple and unambiguous things:

  • Our apps and services include no third-party advertising. We might include advertising in the future. We might not. Like everything else, if we think that it's cool, interesting, or informative and that you might think so, too, we may want to share it with you.
  • Shades does not sell your information to any Advertisers (or anyone else).
  • We do not transfer any of your personal data outside of the United States.
  • We do not use any sort of cross-site tracking that follows your activities around the internet. If you create a shades account , we may collect information on how you use our site or services so that we can improve your experience or surface better or more relevant content to you.

Scope

This Privacy Policy explains our practices regarding the collection, use and disclosure of information that we receive when you use our Services. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Any information that we collect is subject to the Privacy Policy in effect at the time that information is collected.

Updates to this Privacy Policy

We may modify and revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we'll notify you of those changes by posting them on the Services or take other actions as required by applicable law, and we'll indicate when those changes will become effective. Also, please note that, unless we define a term in this Privacy Policy, all capitalized words used in this Privacy Policy have the same meanings as in our Terms of Service.

Products and Services

There are several ways that you might encounter and use shades's services.

For iPhone users, we offer a native iOS app in Apple's App Store.

For Android users, we offer a native Android app in the Play Store.

shades's service is also available at the website located at www.shades.news

For purposes of this Privacy Policy, our iPhone and Android practices are assumed identical unless otherwise stated and referred to as our "mobile" practices.

Information We Collect

To provide our Services, we collect:

  1. Information Provided by You or Collected with Your Permission
  2. Information Related to Your Use of the Services
  3. Information from our Partners

Information Provided by You or Collected with Your Permission.

  • User Data (mobile): When you first install and setup our App, we may collect information about you as provided by the Apple App Store or Google Play Store. When you set up your own account or otherwise interact with our Services, we may also collect certain personal information that can be used to identify you, which may include your name, your e-mail address, your profile image and other information. In the future, we may release functionality that allows you to share your thoughts with the shades community. Such audiovisual data as you might upload to shades in such cases would be considered User Data within the meaning of this Privacy Policy.

  • Survey Data: We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information that may include personal information. Such information is treated as User Data within the meaning of this Privacy Policy.

Information Related to Your Use of the Services

  • Device Data: We and third parties we work with may automatically collect certain data about the device you use to access our Services. This data may include your Internet Protocol (IP) address, mobile advertising identifiers (Google Advertising ID or Apple Advertising ID) and other unique identifiers, cookie identifiers, model name, operating system, country code, app version, and other user settings and preferences.
  • Activity Data: We automatically collect certain data about your activities on our Services, including the pages, content or features of our Services you browse and the time you spend on those pages, content or features, the hyper-links from the contents displayed on our Services that you click on, referrer information and other information about how you use our Services.
  • Location Data: In the future, you may provide us with your location data. We will collect information about your location when you enable this feature on the Services. In addition, we may also infer your location based on your IP address and use various other technologies to determine your approximate location, such as sensor data from your device that provides information on nearby Wi-Fi access points and cell towers.

Information from Our Partners.

  • Third-Party Partners: We may receive your information from our partners, such as publishers, advertisers, and third-party data providers. Our partners may provide information about your activities and interests off our services, including information about your device, device identifiers, your precise or approximate location, websites and advertisements you interact with, your browsing patterns, and information about how you use our partner's services.

How Do We Use Information?

Our primary purpose for collecting and using information is to deliver quality information and Content to you, our users. We also collect and use your information for a variety of business purposes, including:

  1. To Provide the Services or Information Requested
  2. To Measure Performance and Carry Out Research
  3. For Customer Support
  4. For Administrative or Legal Purposes

To Provide the Services or Information Requested. This includes using your information to:

  • Fulfill our contract with you;
  • Tailor and deliver Content curated according to your interests which we infer from the data we collect;
  • Provide access to certain functionalities, and features of our Services;
  • Create and update your account; and
  • Manage your information.

Information Provided by You or Collected with Your Permission:

  • Measure interest and engagement in the Services;
  • Pursue our legitimate interests, such as research and development (including marketing research), network and information security, and fraud prevention;
  • Improve our products and Services;
  • Develop new products and services; and
  • Carry out analysis. For example, we may use personal information and other data to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

For Customer Support. This includes using your information to:

  • Respond to questions, comments, and other requests from you;
  • Investigate and answer requests for customer or technical support; and
  • Communicate with you about activities on the Services and changes to our Terms of Service.

For Administrative or Legal Purposes. This includes using your information to:

  • Ensure internal quality control and safety;
  • Verify individual identity to respond to certain requests or claims;
  • Carry out audits;
  • Prevent and prosecute potentially prohibited or illegal activities;
  • Enforce our agreements; and
  • Comply with our legal obligations. For example, we may disclose your information to certain government entities regarding certain claims or disputes relating to use of our Services.

What Information Do We Share With Third Parties?

We may share the information that we have collected from you:

  1. With Our Service Providers
  2. With Your Consent or at Your Request
  3. With Affiliates
  4. For Legal Reasons
  5. In Connection with Business Transactions

Information Shared with Our Service Providers.

We may engage third party service providers to work with us to administer and provide the Services. The types of service providers to whom we entrust information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) analytics; (iv) marketing and advertising; (v) customer service activities; and (vi) the provision of IT and related services.

We also use analytics services from Google including Google Analytics for Firebase to collect analytics information on the Services. For more information about Google's processing of your information, please visit: https://policies.google.com/technologies/partner-sites. To learn more about how to opt-out of Google Analytics' use of your information on our website, please visit: https://tools.google.com/dlpage/gaoptout.

Information We Disclose with Your Consent or at Your Request.

We may share your information with third parties if you provide us with your consent or if you have expressly requested that we share your information.

Information Shared with Affiliates.

We may share personal information with our affiliated companies.

Information Disclosed for Legal Reasons.

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

Information Shared in Connection with Business Transactions.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

OPT-OUT OF MARKETING EMAILS OR NEWSLETTERS

When you receive promotional communications or newsletters from us, you may “opt-out” by following the unsubscribe instructions indicated in the communication you receive. You may also opt-out of receiving newsletters and/or promotional communications through the Notifications settings in your Account settings page at shades.news. We may continue to send you communications regarding the Services, such as notices about administrative updates, transaction reports, and changes to the Services, this Privacy Policy or the Terms of Service.

Cookies and Third-Party Technologies

Cookies and Pixel Tags. Unless you're logged in, we try to leave you alone. We don't drop cookies for simply visiting the website, as other sites do. We don't track what other websites you've visited or may be visiting. We think that's invasive. Once you create an account, then we might use cookies, pixel tags, and other similar technologies to improve your experience. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. Our use of cookies and similar technologies falls into the following general categories: (i) operationally necessary; (ii) performance-related; (iii) functionality-related; and (iv) advertising-related.

Software Development Kits. We may use third party software development kits (“SDKs”) as part of the functionality of our App. SDKs typically collect your mobile device identifier and information related to your use of the Services. SDKs may allow third parties including analytics and advertising partners to collect your information for various purposes including to provide analytics services and personalized advertising. For more information about the SDKs we use, please contact us as set forth below.

Your Choices

General. You may have the right to opt out of certain uses of your information.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Service or this Privacy Policy).

Mobile Devices. We may send you push notifications through our App. You may opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect precise location information if you enable such collection via our App. You may opt-out of this collection by changing the settings on your mobile device.

Individual Rights in Personal Information

In accordance with applicable law, you may have the right to:

  • obtain access to or a copy of your personal information with accompanying details;
  • receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”);
  • change or update your personal information;
  • withdraw your consent to process your personal information;
  • request that we restrict or limit our use of your personal information;
  • request erasure of personal information held about you by shades; and
  • object to our processing of your personal information.

If you would like to exercise any of these rights, please send an email to legal@shades.news and specify the nature of your request in the email you send. If you have any questions, please contact us as set forth below. Please note that there may be technical limitations that prevent us from fulfilling certain requests. We may carry out deletion requests by de-identifying and/or anonymizing information such that it is no longer personal information.

We will process such requests in accordance with applicable laws. To protect your privacy, shades will take steps to verify your identity before fulfilling your request. In order to verify your request, we use an identifier that is unique to your device that has been assigned by our App. If you submit a request in accordance with the instructions listed above, we will automatically receive the identifier. If we do not receive this identifier when you make a request, we will not be able to verify your identity and will deny your request.

How Long Do We Retain Your Information?

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

The Security of Your Information

We take reasonable measures to protect the information that we collect from or about you from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on our Services, by sending an email to you, or through other means.

Supplemental Notice for California Residents

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information shades has collected about them and whether shades disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by shades

Category of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers

  • Our affiliates
  • Service providers

Personal information categories listed in Cal. Civ. Code § 1798.80(e)

  • Our affiliates
  • Service providers

Protected classification characteristics under California or federal law

  • Our affiliates
  • Service providers

Commercial information

  • Our affiliates
  • Service providers

Internet or other electronic network activity

  • Our affiliates
  • Service providers

Geolocation Data

  • Our affiliates
  • Service providers

Inferences drawn from other personal information to create a profile about a consumer

  • Our affiliates
  • Service providers

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

Additional Privacy Rights for California Residents

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 18 years of age. Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us at legal@shadesme.

LOCATED IN THE UNITED STATES

shades and the Services are located in the United States and governed by US law. If you are outside the United States when you visit the Services or engage in communications with us, please be aware that your Personal Information may be transferred to, stored and processed in the United States where our servers are located. Any information you provide to us, or that we collect through your use of the Services and will be stored, processed, and transferred within, or to, the United States. Please be aware that the United States and jurisdictions other than the one in which you are located may not provide the same level of data protection as considered adequate in your country. Note that your Personal Information may be available to the US Government or its agencies under legal process in the United States.

USERS IN THE EUROPEAN ECONOMIC AREA (EEA), UNITED KINGDOM AND SWITZERLAND

The Legal Basis for Using EEA, UK and Swiss Personal Information

For residents of the European Economic Area (EEA), United Kingdom and Switzerland, we advise that your Personal Information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”). Our legal basis for collecting and using your Personal Information is to do so with your consent; where we need the Personal Information for performance of a contract or requested service, including to provide you with our daily Newsletter, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collected your Personal Information with your consent, you may withdraw your consent at any time.

To exercise rights under the GDPR, please initiate your request by emailing us at legal@shadesme.

Our retention of your Personal Information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt-out from receiving such future communications.

To the extent that we transfer Personal Information from the EEA, UK or Switzerland to a jurisdiction outside the EEA, UK or Switzerland that has not been adduced by the European Commission as providing adequate data protections (such as the United States), we will ensure that such Personal Information is safeguarded through appropriate contractual terms or other approved mechanisms.

Rights for EEA. UK or Swiss Residents

In addition, if you are a resident of the EEA, UK or Switzerland, you have the right to:

Find out if we use your Personal Information, to access your Personal Information, and receive copies of your Personal Information. Withdraw any express consent that you have provided to the processing of your Personal Information at any time without penalty. Access your Personal Information and have it corrected or amended if it is inaccurate or incomplete. Obtain a transferable copy of some of your Personal Information which can be transferred to another provider when the Personal Information was processed based on your consent. If you believe your Personal Information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim. Request your Personal Information be deleted or restricted under certain circumstances. For example, if a business is using your Personal Information on the basis of your consent and has no other legal basis to use such, you may request your Personal Information be deleted when you withdraw your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

If we ask you to provide Personal Information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Personal Information is required and if not, the consequences of not sharing your Personal Information with us.

Similarly, if we collect and use your Personal Information in reliance on our or a third party’s legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.

We endeavor to apply suitable safeguards to protect the privacy and security of your Personal Information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy.

To withdraw consent or exercise these rights, please contact us via email at legal@shadesme.

If you are not satisfied with our response, or believe we are processing your Personal Information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your EEA Member State or Switzerland.

  1. SECURITY

shades has implemented technical, administrative and physical security measures to protect your information from unauthorized access and use as described. While we strive to protect your information, no data transmission over the Internet is 100% secure and, consequently, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of any information you transmit you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.

We will retain your information for the time necessary to provide a requested service, realize our legitimate business purposes and to comply with the law. We will only retain personal information for the longer of the period if: (a) required by law, or (b) there is a time-bound determination business need.

Links to Other Services

Our Services may contain links to other websites and services, including News and Entertainment Content. Any information that you provide on or to or that is collected by a third-party website or service is provided directly to the owner of the website or service and is subject to that party's privacy policy. Our Privacy Policy does not apply to such websites or services and we're not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information, we recommend that you carefully review the privacy policies of other websites and services that you access. Visiting these other websites or services is at your own risk.

Our Policy Toward Children

Our Services are not directed to children under 13 and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information of a child under 13 we will take steps to delete such information from our files as soon as possible.

Questions?

Please contact us at legal@shades.news if you have any questions about our Privacy Policy. If you have a question about the shades App, please write to support@shades.news